Arizona’s Nonpoint Source Pollution Reduction Grants Subsidized Arizona Ranchers

The nonpoint source pollution reduction program administered by the Arizona Department of Environmental Quality (ADEQ) is another one of the bewildering array of government assistance programs that has provided subsidies to the state’s public land ranchers.

The program’s grant money comes from the U.S. Environmental Protect Agency (EPA) because the program was created when Congress, by a wide margin, overrode a veto by Pres. Ronald Reagan and passed the Water Quality Act of 1987, which made improvements to the 1972 Clean Water Act, including the creation of the Section 319 Nonpoint Source Management Program. Section 319 was the first federal attempt to directly address the widespread problem of nonpoint source (NPS) pollution, which accounted for as much as 50% of pollution in U.S. waterways.

As the name suggests, NPS pollution doesn’t originate from a specific point, but from many diffuse sources. In rural areas, it’s usually caused by runoff from poorly managed agricultural operations. In the Southwest, it’s often caused by ranching in the form of increased sediment in stream water due to accelerated erosion caused by poorly managed livestock grazing. Also, the runoff sometimes carries the dangerous pathogen E. coli from livestock feces.

The creation of the federal Section 319 program required each state to conduct NPS pollution assessment reports, identify best management practices (BMPs) to reduce the problems identified, and submit state NPS management programs to the EPA for approval. But these mandates were relatively toothless. The only serious leverage the EPA had was to make states ineligible to receive federal money for the new NPS pollution prevention cost-sharing grants if they failed to comply.

SB 1103

The Arizona Legislature significantly revised the state’s NPS pollution prevention program in 1997 with passage of SB 1103. The bill originated in the Senate as a reauthorization of existing agricultural BMP advisory committees. But when it got to the House, Rep. Bill McGibbon, R-Green Valley, a rancher, introduced a floor amendment that created a new surface water quality grazing permit which granted all Arizona ranchers automatic compliance with NPS pollution prevention requirements. The new statewide permit was predicated on the presumption that ranchers would automatically comply with some state grazing BMPs that would be drafted by a new Grazing BMP Advisory Committee. The eight-member Committee included representatives from the state departments of Environmental Quality, Agriculture, and Water Resources, in addition to a representative from the University of Arizona’s College of Agriculture. The other four members were ranchers appointed by the governor. SB 1103 specified that the BMPs recommended by the Committee could not cause a “significant reduction of grazing activity,” and that compliance would be explicitly voluntary, as per ARS § 49-202.01.

Obviously, one of the Legislature’s objectives was to try and have as few strings as possible attached to the federal Section 319 grants. The EPA helped ADEQ move towards that goal when it published new regulations in 1999 designed to improve its relationships with the states by entering into partnership agreements to give the states “increased flexibility” by providing them with annual environmental block grants, including Section 319 money for the state’s to administer on their own.

ADEQ quickly finalized an NPS partnership agreement with the EPA and in 2000 began accepting applications for Section 319 grants – which they renamed Water Quality Improvement Grants (WQIG). Also, the Grazing BMP Advisory Committee got busy and met several times in 2000, which resulted in new BMP rules being published in section R18-9-501 of the Arizona Administrative Code (AAC) early 2001. They were more like guidelines than actual rules. (The Legislature conducted a sunset review of the Grazing BMP Advisory Committee in 2006, and determined it had served its purpose of preempting stricter federal NPS regulations. Subsequently, in 2007 the Legislature passed HB 2487 to have the committee absorbed by the Agricultural BMP Advisory Committee.)

Since ADEQ began administering the WQIG program in 2000, the agency has awarded many grants to ranchers permitted to graze their livestock on public land managed by the managed by the Forest Service the Bureau of Land Management (BLM). Some of these cost-sharing grants have helped to fund projects that definitely benefited riparian areas and improved stream water quality – but they were still subsidies. There are serious questions, however, about the appropriateness of some of the grants, including the examples listed below.

Grants To HRM Ranchers

As mentioned above, the EPA was in charge of awarding Section 319 grants in Arizona prior to when ADEQ took over the program in 2000. But ADEQ solicited NPS grant applications in the state during those early years and during that time they succeeded in convincing the EPA to fund at least two holistic resource management (HRM) ranch demonstration projects. HRM livestock management schemes have been promoted in response to the growing controversy about permitting livestock grazing on public land. Proponents of HRM claim that it can resolve this political conflict with win-win solutions wherein ranchers can put more cattle on the land while, at the same time, wildlife habitat can be improved. The problem is that HRM isn’t science-based, and a growing body of research has long shown that claims made by its proponents aren’t true. The EPA, however, still agreed to award two Section 319 demonstration grants to help fund HRM projects in Arizona in the 1990s.

Section 319 Grant #90-004 was awarded for $175,600 in 1990. The project was implemented on the Yavapai Ranch, which includes the Prescott National Forest’s Yavapai Grazing Allotment. The Arizona State Land Department’s Chino Winds Natural Resource Conservation District (NRCD) took the lead in drafting a coordinated resource management plan (CRMP) to justify the project. This was despite the fact the federal USDA’s Natural Resources Conservation Service (NRCS) had drafted a conventional, science-based, rest-rotation grazing plan for the ranch in 1986. The implementation of the intensive HRM grazing system required the construction of 54 miles of fence, 30 miles of water pipelines, 21 water storage tanks, and 33 cattle watering troughs. It was supposed to improve upland range conditions, and thereby increase downstream water quality. The project monitoring showed the HRM system didn’t produce the expected results. The total amount of government assistance that’s known to have benefited the Yavapai Ranch is listed in the table below.

Government Assistance For Ranchers Program Key
AALB - Arizona Livestock Loss Board, Arizona Livestock Loss Board (federal/state)
AWPF - Arizona Water Protection Fund, AWPF Commission (state)
ECP - Emergency Conservation Program, USDA’s Farm Service Agency (federal)
EQIP - Environmental Quality Incentives Program, USDA’s Natural Resources Conservation Service (federal)
The EQIP program absorbed the NRCS Wildlife Habitat Incentives Program (WHIP) after 2014.
EWP - Emergency Watershed Protection, USDA’s Natural Resources Conservation Service (federal)
The Arizona EWP Drought Program was discontinued in 2001 after a critical audit.
HPC - Habitat Partnership Committee, Arizona Game & Fish Commission (state)
Arizona Heritage Fund, Arizona Game & Fish Commission (state)
LCCGP - Livestock & Crop Conservation Program, Arizona Department of Agriculture (state)
Note: Open Space Reserve Grants became LCCGP Grants after 2002.
LFP - Livestock Forage Disaster Program, USDA’s Farm Service Agency (federal)
LOFFAP - Livestock Operator Fire & Flood Assistance Program, Arizona Department of Agriculture (state)
LRP - Landowner Relations Program, Arizona Game & Fish Department (state)
PFWP - Partners for Fish & Wildlife Program, U.S. Fish & Wildlife Service (federal)
WHREF - Wildlife Habitat Restoration & Enhancement Fund, Arizona Game & Fish Department (state)
This fund was created by a one-time $3.5 million appropriation by the Legislature in 2006.
WQIG - Water Quality Improvement Grant, Arizona Department of Environmental Quality (federal/state)
Note: These grants were previously called Section 319 nonpoint source (NPS) water pollution prevention grants.
Yavapai Ranch (Yavapai Ranch LLLP) - Yavapai Allotment
1990ADEQ NPS Grant #90-004$175,600Chino Winds NRCD HRM Demonstration Project
2015Heritage Fund$30,000Public Access for 2 Years
2017HPC #16-305$15,900Dirt Tank Cleanouts
2017HPC #16-308$33,831Install Solar Water Pumps
$1,596,119TOTAL 1990-2022

Another HRM project on the BLM’s Pratt Tank Grazing Allotment, located in the Arizona Strip, received Section 319 Grant #95-002 for $70,800 in 1995. It was supposed to show that feeding a herd of 400 cattle confined to a relatively small pasture of sagebrush would kill the sagebrush and increase the ground cover, especially grass, thereby reducing erosion and nonpoint source water pollution downstream. But, like the previous Chino Winds HRM project, it didn’t produce the expected results. Lisa Nelson, the EPA’s regional NPS pollution prevention manager at the time, approved the grant for this Ungulate Action project. She admitted it “sounded weird” when she heard the proposal for the first time. “We have no hammers, no nonpoint source regulatory authority,” she explained afterwards. “All we have is the Section 319 grants. We are trying to foster a community awareness about this type of pollution.”

ADEQ Begins Administering The Grants

ADEQ should have learned from these failed HRM ranch projects, but instead, they continue to fund more of them after they began administering the WQIG program in 2000.

In 2002 it awarded WQIG #4-012 for $55,700 to EcoResults, Inc., a contractor that used HRM, in order to implement some livestock management measures on the Rio Verde and Y Bar D ranches located in the Prescott National Forest along the upper Verde River. The grant was used to help fund a project that was supposed to include “state-of-the-art” techniques, but most of them were common measures, such as building fences, and cutting down juniper trees to grow more grass for cattle. The project’s uniquely HRM measure of having cattle stomp hay and seeds into the ground to promote the growth of vegetation was a complete failure.

Grants With Potential Conflicts Of Interest

All WQIG recipients are required to sign a Terms and Conditions agreement to comply with federal law which includes a Section 9.1, that states:

Conflict of Interest. The Grantee shall comply with standards of conduct pursuant to 40 CFR § 31.36 to avoid conflict of interest. Recipients of federal funds may not participate in the selection, award, or administration of a contract if real or apparent conflict of interest would result.

This regulation specifically states that this includes contracts made with “any member” of the “immediate” family.

WQIG #20-008 for $188,911 was awarded in 2020 to Knight Environmental, owned by Daric Knight, to repair sediment basins (stock tanks) on the ranch of Galyn & Roxanne Knight – Daric’s parents. The total amount of government assistance that’s known to have benefited the Knight’s ranch is show in the table below.

Cinco Noches Ranch (Galyn & Roxanne Knight) - Hayground/Reservation & Colter Creek Allotments, State Leases #05-001662 & #05-085885
1999EWP$23,453Paid to Take Cattle Off the Land During Drought
2000EWP$8,422Paid to Take Cattle Off the Land During Drought
2002OSR #1$25,552
2005LCCGP #05-55$43,306Livestock Water and Fencing
2012WQIG #12-002*$494,087Improve Coyote Creek Watershed Degraded by Livestock Grazing
2018WQIG #20-008**$188,911Sediment Basin (stock tank) Rehabs
$1,520,896TOTAL 1999 - 2022

* Open Space Reserve (OSR) grants became LCCGP grants in 2005.
** The contractor for this project was the Knight’s son Daric Knight.

In 2008 ADEQ awarded WQIG #10-008 for $126,900 to help build 7.4 miles of livestock fence in the Gila Box Riparian National Conservation Area (RNCA). This project was on the Noland Ranch, which was located in Greenlee County and included the BLM’s Turtle Mountain, Morenci & Metcalf allotments, along with the Granville allotment on the adjacent Apache Sitgreaves National Forests, and also a couple of subleased Arizona state land grazing leases. The fence helped protect important riparian habitat from cattle, but a closer look at the grant’s financial details raised some troubling questions. The budget page from the grant agreement showed the cost of building the fence included $10,00 per mile for labor, plus $5,000 per mile for foremen, and $9,400 for a project administration fee.

I was curious about why the labor costs to build the fence were so much higher than average. The 2008 quarterly project report submitted to ADEQ by the ranch’s owners that showed the fence construction was completed by a contractor named “Jr’s Fencing of Morenci, AZ.” An online search revealed that Jr’s Fencing shared the same phone number as Noland Tough, a fencing company incorporated in 2009 by the Noland Ranch’s owners. I used the Contact Us form on the Noland Tough website to ask if Jr’s Fencing was the name they had previously used for their fencing company, and on May 26, 2020, I received an email response which confirmed that it was.

Moreover, the labor cost of $15,000 per mile to build the project’s fence was about twice the usual rate in the area. In 2006, for example, the Arizona Water Protection Fund (AWPF) grant #06-135 helped fund the construction of 7.5 miles of new fence on the nearby Double Circle Ranch for the going rate of only $7,000 per mile for labor.

Furthermore, the Gila Box RNCA fence wasn’t the only project in the area that was partially funded by a government grant where a Noland company was the fence contractor and the labor costs were higher than average. A receipt attached to the project record for WQIG #9-003 indicates the Noland’s were the fence contractor for that project too. That $95,100 grant in 2007 helped fund the construction of 5.5 miles of fence on the Double Circle Ranch, and the project’s budget shows the contracted labor to build the fence totaled $97,977, which works out to about $17,814 per mile. The Nolands were also the fence contractor for AWPF grant #11-177 in 2011 for $136,714, which helped fund the reconstruction of 5 miles of fence on the nearby Four Drag Ranch. That works out to about $27,342 per mile, although that includes the cost of materials too.

And these weren’t the only local projects that raised questions about fence costs. The projects partially funded by WQIG #8-007 and WQIG #10-003 appeared to have high fence costs too. I sent the Nolands an email asking if they were the contractors for those projects, but I didn’t receive an answer. So, I subsequently sent another email asking for an explanation of why the fence costs were above average on the projects for which I already knew they were the contractor, but got no response to that either. The table below lists all of the government assistance that’s known to have benefited the Noland Ranch before it was sold to a new owner in 2019.

Turtle Mountain Ranch (Turtle Cattle Co. LLC) - Turtle Mountain, Morenci, Metcalf (BLM) & Granville (FS) Allotments, State Subleases #05-001089, #05-002190
2007LCCGP #07-70$125,000Livestock Water, Fencing
2008WQIG #10-008$126,900Gila Box RNCA Riparian Fence
2008LRP$22,200Gila Box RNCA Riparian Fence
2011LCCGP #11-52$83,910Chesser Creek Rehab
2013HPC #12-502$29,623Turtle Mtn. Allotment Water & Livestock Fence
2014HPC #13-503$33,000Turtle Mtn. Allotment Water & Livestock Fence
2016LCCGP #16-19$47,863Livestock Fence Reconstruction
$1,233,714TOTAL 2007 - 2023
The government assistance disbursed prior to 2019 benefited the ranch's previous owners, Noland Ranch LLC, which sold the to Turtle Cattle Co. LLC ranch in 2019. One of the ranch's current owners, John L. Klump, was convicted in 1998 of selling the hides of endangered jaguars and ocelots.
Grants For Failed Projects

There were three grants for projects on the Sands Ranch that addressed watershed health from 2015 to 2018:

The 62,685 acre Sands Ranch includes Forest Service, BLM, state, Pima County and private land in Pima and Cochise counties. The ranch’s numerous pastures wrap around the southern end of the Whetstone Mountains, with the westernmost ones in the Cienega Creek watershed, and the eastern pastures in the watershed of the Sand Pedro River.

In 2008 Pima County paid $21 million to purchase 5,040 acres of the ranch’s private base property to prevent it from becoming a new housing development, and then leased it back to the seller, Sands Properties LLC, to allow the ranching operation to continue. Before the county purchased the land, it commissioned a biological reconnaissance of the ranch which found that in some places “the native bunch perennial bunch grasses have been much reduced and occasionally eliminated along with most of the other ground vegetation.” It added that these areas, “have also been trampled, pulverizing the topsoil, ” and pointed out that, “these areas are prime areas for subsequent erosion.”

After the county acquired the property, the ranch’s managers worked with the local NRCS office to draft a coordinated resource management plan, which resulted in the Sands Ranch CRMP in 2010. One of the CRMP’s primary objectives was to deal with the ranch’s “impediments to profitability.” The CRMP was used to justify two Water Quality Improvement Grants, #15-001 and #16-002, which totaled $184,272 that helped fund the aerial spraying of the herbicide tebuthiuron to kill brush to grow more grass for cattle. One danger of using tebuthiuron is that, even though it targets woody vegetation, it’s still toxic to a lot of herbaceous plants – including some grasses. This means the land can be practically denuded, and stay that way if there’s drought, leaving no wildlife habitat and little vegetation to hold the soil during rainstorms.

That is what apparently happened, because in 2016 ADEQ awarded grant #18-004 for $130,500 to the Borderlands Restoration Network, a regional nonprofit that promotes a “restorative economy,” to help fund their sheet erosion and E. coli mitigation project on the Sands Ranch. They built small rock erosion control structures on the ranch to catch sediment contaminated with E. coli by cattle, to prevent it from reaching the San Pedro River. The primary area for this mitigation work was described as, “extensive areas east of Hwy 90 previously sprayed with herbicide that have not recovered vegetatively.” The total amount of government assistance that benefited the Sands Ranch is shown in the table below.

Sands Ranch (LS Cattle Co. LLC) - Mescal (FS) and Sands Investment (BLM) Allotments, State Lease #05-001181, Pima County Lease #22-64-S-141624-1208
1999EWP$44,615Paid to Take Cattle Off the Land During Drought
2011LCCGP #11-29$124,000Grassland Restoration, Livestock Water
2014Heritage Fund$34,000Aerial Application of Herbicide to Kill Brush
2014LRP$114,000Aerial Application of Herbicide to Kill Brush
2012HPC #11-510*$18,000Southwest Whetstone Mountains Livestock Water - Phase 2
2015WQIG #15-001$86,163Aerial Application of Herbicide to Kill Brush
2015WQIG #16-002$98,109Aerial Application of Herbicide to Kill Brush & Livestock Water
2018WQIG #18-004$130,500Install Small Rock Erosion Control Structures
$987,518TOTAL 1999 - 2022
Prior to 2012 the ranch was owned by Sands Properties LLC. The Vera Earl Ranch Inc. is a co-owner of the LS Cattle Co. LLC.
* This HPC grant was shared with a neighboring ranch.

In the early 2000s, two grants, WQIG #3-005 & WQIG #7-002 were awarded to help fund the Campomocho-Sacaton Watershed Improvement Plan, which had been promoted by two local ranchers. They were were awarded to the Coronado Resource Conservation & Development Area, Inc., a regional nonprofit organization that helped solicit grants for agricultural interests. But the grants mostly benefited a couple of ranches, the Hook Open A and Redtail ranches, located adjacent to each other in Cochise County north of Willcox. Each ranch held a permit for a grazing allotment in the Coronado National Forest in the southern foothills of the Pinaleño Mountains north of town, and when there was sufficient precipitation, the runoff on the ranches drained south across the state lands leased for grazing in the desert below.

The stated objective of the two grants was to reduce erosion and downstream flooding in the area. The grants helped fund the “ripping” of strips of state land about 50 feet apart with a single plow at a perpendicular angle to the direction of the runoff in order to slow down its flow, and to also create places to plant native grass seeds because grass had become scarce due to overgrazing and drought. The money also helped fund the construction of more than a dozen new “flood control structures” which also just happened to function as dirt stock tanks where cattle could water. But according to an investigation update in the State Land Department’s FY 2009 Annual Report, the tanks were seriously damaged by heavy runoff from a rainstorm shortly after they were built, and two of them completely failed. After an investigation, they were repaired, but the report implied that even more public funds were spent to fix them. (In response to a public record request about the investigation, the State Land Department responded they “do not have the information you are requesting on the subject project.”)

Old City Cemetery, Willcox, Arizona
Old City Cemetery, Willcox, Arizona (Jeff Burgess)
Grants For “Sediment Basins”

ADEQ has disbursed numerous Water Quality Improvement Grants to build new livestock waters on ranches. They were justified by claiming that they would protect riparian areas by drawing cattle away from them to the surrounding uplands. But research (Carter 2017) has shown that new upland waters don’t significantly improve the condition of riparian areas unless the streams are fenced to exclude cattle. These new waters primarily facilitate rotational grazing schemes and more livestock on the surrounding uplands.

Grants have also been issued to help construct and repair sediment basins. The basins are typically created by placing a dirt berm across a dry wash to try and improve water quality downstream by limiting floods when it rains, thus reducing the amount of sediment carried in runoff. Coincidentally, when they hold water, ranchers can use them as stock tanks to water their livestock. These projects, however, rarely address the primary cause of the accelerated erosion, which is often poorly managed livestock grazing.

Grants that funded sediment basin (stock tank) repairs included:

  • WQIG #12-002, Coyote Creek Watershed Ranches, $494,087
  • WQIG #15-005, Upper Little Colorado River Watershed Ranches, $322,822
  • WQIG #20-008, Knight Ranch Sediment Basins Rehab, $188,911
Multiple Grants Benefited A Handful of Apache County Ranches

All three of the grants listed above benefited ranches in Apache County. In fact, as shown in the table below, there were four grants that benefited a handful of Apache County ranchers, and several of them benefited from more than one grant. (Visit the Apache-Sitgreave National Forests Ranches page to see the total government assistance that has benefited these ranches.) As mentioned above, the projects funded by these grants did little to directly address the primary cause of the erosion – livestock grazing.

Water Quality Improvement Grants - Apache County Ranches
YearsWQIGAmountRanch NamesPurpose
2012#12-002$494,087Cinco Noches
Coyote Creek
Horseshoe Springs
Travis Johnson
Improve Coyote Creek Watershed Degraded by Livestock Grazing
Scraper Knoll
Improve Upper Little Colorado River Watershed Degraded by Livestock Grazing
2018#20-007$59,869Rogers/LeeRepair Coyote Creek Streambank
2018#20-008$188,911Cinco NochesSediment Basin (stock tank) Rehabs
Grants to Kill Trees

ADEQ has disbursed many NPS grants to manipulate native vegetation by killing “invasive” brush and trees to try and grow more grass. The projects were typically labeled as grassland or watershed restorations, and claimed that grass is inherently superior to woody vegetation in reducing erosion. But research (Belsky 1996, Collings 1966, Perkins 2005, Wilcox 2002) has shown that there’s no significant difference in streamflows, water yields, and sediment loads between healthy woody and herbaceous vegetation communities in the arid Southwest. Sometimes the trees were killed mechanically, but often they were killed by aerial spraying of dangerous herbicides. The real primary objective of these projects wasn’t NPS pollution production, but to grow more herbaceous forage for cattle.

Furthermore, many of these projects were just treating symptoms, not the causes. One of the primary causes of the recent proliferation of woody vegetation is that cattle prefer to eat herbaceous vegetation, like forbs and grasses, which provide the fine fuels necessary for the periodic, milder fires that naturally control woody vegetation. If cattle grazing isn’t concurrently reduced when the woody vegetation is killed, the process can repeat itself. And increases in woody vegetation might recurr anyway because of ongoing climate change.

The Arizona Game & Fish Department (AGFD) bought into this vegetative manipulation strategy because grasslands also benefit certain big game species. In 2015 they were awarded with WQIG #EV15-0005 for $412,000 for the ADEQ/AGFD Watershed Restoration and Protection Funding Partnership. A lot of this money was undoubtedly spent by AGFD to kill trees to promote the growth of more grass.

For instance, AGFD was subsequently awarded WQIG #19-0010, for up to $109,176 to to kill mesquite trees in the Altar Valley. It was justified by claiming it would reduce NPS pollution in the form of sediment washed into Brawley Wash, an ephemeral Sonoran Desert wash that drains the valley, and only runs after heavy rains. The true purpose, however, was to improve habitat and hunting opportunities for pronghorn antelope, which prefer wide open spaces.

Mesquite trees, however, are a keystone desert plant, and vegetation species (Tiedemann 2004) and wildlife species (Germano 1983) are more numerous in areas with mesquites.

Response of Selected Wildlife Species to the Removal of Mesquite from Desert Grassland

At higher elevations, juniper trees were the target of these types of vegetation manipulation projects. They also provided more forage for cattle, while elk were usually the local big game species that benefited from them. The ranch in the table below received two WQIG grants that included money to kill juniper trees.

M Diamond Ranch (M Diamond Management Co. LLC) - Buckhorn Allotment
2002Heritage Fund$31,300West Clear Creek Riparian Fence
2004WQIG #5-012$119,100Livestock Fences & Waters
2004HPC #03-2-040$29,850Remove Pinyon Pine & Juniper Trees
2004HPC #03-2-041$29,850Remove Pinyon Pine & Juniper Trees
2005WQIG #6-019$224,177 Livestock Fence, Remove Juniper Trees
2005LCCGP #05-63$75,000Grassland Restoration & Erosion Control
2007LCCGP #07-58$26,100Fencing
2008HPC #07-216$16,000Remove Pinyon Pine & Juniper Trees, Install Cattle Guards
2018HPC #17-204$20,000Livestock Water Enhancement
2018WQIG #20-006$71,364Clean Stock Tanks, Remove Juniper Trees
$927,334TOTAL 2002 - 2022

Note: All financial information obtained by federal Freedom of Information Act requests, and state Public Records Requests.


WQIG Awards state FY2014 – FY 2020

EPA’s NPS Grants Reporting and Tracking System (GRTS) 

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